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BRYS DECL. ISO SJ REPLY
CASE NO. 3:21-MD-02992-GPC-MSB
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW
JAMES W. MCGARRY (pro hac vice)
JMcGarry@goodwinlaw.com
GOODWIN PROCTER LLP
100 Northern Avenue
Boston, MA 02210
Tel.: +1 617 570 1000
Fax: +1 617 523 1231
SABRINA M. ROSE-SMITH (pro hac vice)
SRoseSmith@goodwinlaw.com
MATTHEW L. RIFFEE (pro hac vice)
MRiffee@goodwinlaw.com
GOODWIN PROCTER LLP
1900 N Street, NW
Washington, DC 20036
Tel.: +1 202 346 4000
Fax: +1 202 346 4444
Attorneys for Defendant
BANK OF AMERICA, N.A.
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF CALIFORNIA
SAN DIEGO DIVISION
IN RE: BANK OF AMERICA
CALIFORNIA UNEMPLOYMENT
BENEFITS LITIGATION
Case No. 21-MD-02992-GPC-MSB
DECLARATION OF LAURA G. BRYS
IN SUPPORT OF DEFENDANT BANK
OF AMERICA, N.A’S REPLY IN
SUPPORT OF ITS MOTION FOR
PARTIAL SUMMARY JUDGMENT
(ECF 589)
Ctrm:
12A – 12th Floor
Judge:
Hon. Gonzalo P. Curiel
Case 3:21-md-02992-GPC-MSB Document 693-3 Filed 02/20/26 PageID.59509
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BRYS DECL. ISO SJ REPLY
CASE NO. 3:21-MD-02992-GPC-MSB
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW
I, Laura G. Brys, state and declare as follows:
1.
I am an attorney licensed to practice before this Court.
2.
I am a senior attorney at Goodwin Procter LLP, and counsel of record
for Defendant Bank of America, N.A. (BANA) in the above-captioned lawsuit.
3.
I have personal knowledge of the facts set forth in this declaration, and
if called upon to do so, I could and would competently testify thereto.
4.
I make this declaration in support of BANA’s Reply in Support of its
Motion for Partial Summary Judgment (ECF 589).
Expert Declarations and Reports
5.
Attached hereto as Exhibit 185 is a true and correct copy of the
Declaration of Victor Stango in Support of Defendant’s Reply in Support of its
Motion for Partial Summary Judgment dated February 19, 2026.1
Deposition Transcripts
6.
Attached hereto as Exhibit 186 is a true and correct copy of excerpts of
the official transcript of Plaintiffs’ deposition of Faiz A. Ahmad, taken on January
29, 2025.
7.
Attached hereto as Exhibit 187 is a true and correct copy of excerpts of
the official transcript of Plaintiffs’ deposition of Shane Daniels, taken on February 6,
2024.
8.
Attached hereto as Exhibit 188 is a true and correct copy of excerpts of
the official transcript of Plaintiffs’ deposition of Jennifer Ehresman, taken on
February 19, 2025.
9.
Attached hereto as Exhibit 189 is a true and correct copy of excerpts of
the official transcript of Plaintiffs’ deposition of Anne Holt, taken on January 8, 2025.
1 For purposes of this Reply and the Opposition to Plaintiffs’ motion to exclude
(ECF 659), the numbers contained in Paragraphs in 6a.-6b. of the Stango Decl. (HX
185) supersede the numbers reflected in Decl. of Lindsay E. Hoyle in Support of
Defendant Bank of America, N.A.’s Opposition to Plaintiffs’ Daubert Motion to
Exclude Certain Testimony of Victor Stango (ECF 659-1), which reflected the
number of claims at issue as opposed to the total number to class members, some of
whom filed multiple claims.
Case 3:21-md-02992-GPC-MSB Document 693-3 Filed 02/20/26 PageID.59510
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BRYS DECL. ISO SJ REPLY
CASE NO. 3:21-MD-02992-GPC-MSB
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW
10.
Attached hereto as Exhibit 190 is a true and correct copy of excerpts of
the official transcript of Plaintiffs’ deposition of Teresa Pesce, taken on May 8, 2025.
11.
Attached hereto as Exhibit 191 is a true and correct copy of excerpts of
the official transcript of Plaintiffs’ deposition of William Golden, taken on February
22, 2024.
12.
Attached hereto as Exhibit 192 is a true and correct copy of excerpts of
the official transcript of Plaintiffs’ deposition of Robert A. Chestnut, taken on
February 8, 2024.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 20th day of February, 2026, in Los Angeles, California.
s/ Laura G. Brys
LAURA G. BRYS
Case 3:21-md-02992-GPC-MSB Document 693-3 Filed 02/20/26 PageID.59511
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